Raw Truth. Real Health

Episode 9 - Pet food labelling and manufacturing standards. What you should expect!

• Dr. Roz (PhD) • Season 1 • Episode 9

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In this episode I unpack the Australian Standards for Pet food Manufacturing - including in-feed supplements and give some examples where and why we need to push companies to step up their game. We're quick to critique dry food companies but many are not close to compliant in their labelling and manufacturing standards! 

To follow and connect with Dr. Roz and Australian Pet Nutrition
Follow on socials - @australianpetnutrition or connect for education, nutraceuticals, food and more at australianpetnutrition.com.au

Dr. Roz (00:50)
and welcome back to another episode of Raw Truth, Real Health. Today, you have just me talking about a topic that is really, really close to my heart, and that's pet food labeling and pet food manufacturing standards. Now, what I'm going to be referring to today is actually what everyone who bags or rebags, manufactures treats, makes pet food, makes pet supplements, makes anything that is

edible, essentially, in the pet food industry. And the number of businesses that write to me when I've talked about this on our Instagram previously, and is not aware of it, absolutely blows my mind. Now, the reason I'm so passionate about this is I don't understand why more transparency from companies is not there in their packaging, is not there in their manufacturing procedure. If we genuinely care about

pets and pet health and we have nothing to hide as a business, why not include more information for consumers to understand about the product, but also to make better informed choices about their pets' health and not mislead people? In my opinion, we've got over 90 % of the industry not compliant even to these basic standards that are so basic that also

have so much leeway that people can mislead, ⁓ that we just shouldn't be doing that in this day and age. And businesses should not be making claims about being passionate about pet health and being transparent and dissing kibble companies if you yourself are not compliant or you yourself are not being fully transparent, even more transparent than the standards ⁓ suggest. So it's time I think that we as.

pet businesses, take a long hard look at ourselves and instead of throwing stones, maybe do a bit of self reflection and see if we can improve our standards, improve our labeling, make it easier and more transparent for pet owners to make informed choices about what they're purchasing to put in their pets' mouths. Now, the standards that I'm referring to are federal standards, it's not state by state. The ⁓ licensing for manufacturing

varies from state to state. Each state has a different licensing body, but each state's licensing body asks you to adhere to these standards, which were reissued in 2023, has an updated version. And then the manufacturing and marketing of pet food for dogs and cats are the Australian standards. Now, businesses are required to buy these standards. They're $147. So if you're a business and you haven't read these, start by going and buying this for $147. Some licensing spot

licensing bodies will actually kindly gift these to you, but this should be your Bible and this should be the minimum of what you're doing. There is so much room outside of these guidelines to be more compliant and more transparent. These are, just like I talk about when we talk about complete and bad, the minimum standard. So I'm gonna be talking about these today. I've also de-identified a number of labels to talk about where I think it's misleading and why the hell can we not just be more transparent?

I pride ourselves, Australian pet nutrition, on being super transparent and when people ask for more information, will give it. But generally speaking, all the information is there on the label or on the website as well. It's just, it blows my mind that we think it's okay to disc kibble companies because we're pro raw feeding, but in fact, they're arguably more compliant in their labeling. Okay, their ingredients might be crap, but we're not talking about

the quality of ingredients here. What we're talking about is compliance. What we're talking about is transparency for pet owners. And that should be a priority ⁓ to help in that decision making process. If you're misleading, we're no better. So it's again, like I said, it's time we reflect and look at ourselves. Now I'm going to pick some key things from these because there's a lot of pages to it. And I want to keep this as concise as possible.

but also encourage both pet owners ⁓ to push businesses more, to be more transparent and to encourage them to have better labeling. But also businesses go and read this. You should be reading it however often you audit. If you are auditing yourselves, ⁓ hopefully at least once a year in line with your licensing renewals ⁓ to improve what you're doing. And that should be something that we just do as businesses.

and pride ourselves on. So I'm going to pick some key things that I think are really important in these standards to highlight to everyone in a discussion that I think should be happening a lot more. ⁓ And I really think, and I'm going to say it again, yes, we're a raw food and nutraceuticals company, but kibble companies, generally speaking, are a lot more compliant than these backyard raw food businesses and other supplement companies. So it's time for everyone to pull their socks up ⁓ as

We are in a growing industry and we owe it to pet owners to be more compliant, be more transparent, to help them make more educated, informed choices about their food and supplements. So the first thing, and I've highlighted lots of things in here, that in this guide, if you are claiming that you are selling complete and balanced pet food, two pages in, it gives you links.

to AFCO and FDIF guidelines around what fits those nutritional requirements. So, can't get part stage two without clicking a link to go and see if your nutritional analysis at least meets the minimum of AFCO and FDIF. So that's a real starting point for everybody. Then, the next page literally refers to a guaranteed analysis. So regardless of whether you're complete or balanced,

It's something to consider. Can you guarantee what's going into each batch of yours? ⁓ If you are complete and balanced, you need to have a guaranteed analysis. You should have done a guaranteed analysis and you should have accessible to the public a nutritional profile of that blend or of that particular food type.

Right. Now this is something that I want to read explicitly from the guidelines because it's about product claims. Now we've seen it. We see it all the time with these fancy marketing campaigns, influencers being paid to claim things on products that are just simply not true. And these are part of these standards. So text or pictorial information on a pack that specifically relates to the pet food product.

which may be implied or stated directly. So if you are making implications about a product, that is a claim. So think about what we're saying on our labels, and I'm gonna give some examples later as to whether we are in fact implying something that is not true about our products. It's just simply not okay. Also in these guidelines is how carbohydrates are calculated in a percentage.

There's so many people, particularly nutritionists too, that are arguing this. This is set out in the standards, how to calculate the formula. ⁓ And that should be something that we are all calculating. Also following, it actually comes out of nutritional guidelines and they've referenced that in the standards. But stop saying it's not one way to calculate. These are the standards, these are the pet food standards. So if we are all calculating it the same way, we're all being accurate.

That's literally five pages into the guidelines. Very, very important. Now something so simple, I did a little audit at our local pet food shop where our brand is stocked and half of the products had use by dates. The others did not. It shouldn't be that, it should be 100%. It's in the standards which our licenses are guided by. You do not have a use by date on your product.

Maybe check that. How does a consumer know if what they've bought from a retailer is even in date? How does a retailer know that what they're selling is even in date? How do you keep track of what you've made is even in date? Simple things. And there's more on that, but it's a safety thing. ⁓ It's a safety thing for our pets, but it's a safety thing for our own brand. So again, I'm only five pages in and a 50 %

of one shop didn't have use by dates? What are we doing guys? Honestly, what are we doing?

in these guidelines. If you don't have a QA system as a business, or you cannot outline your QA system to your customers, I don't understand why you wouldn't want to tell them what your quality assurance measures are for your brand. Think again. This is, and this is basic, like this is nine dot points of what QA procedures have to be in place for your licensing. I know they're not being checked, but that's kind of on us.

We should be proud of our brand and proud of the QA we have and not just dismiss it and not do it. Now, when I've worked with other brands in product development, this is the first thing I make them go and print and tell them to read because that's what I'm referencing when I'm helping them develop products. This is what everything should be based on. So we can say it's not a regulated industry. It is regulated and that the standards exist. We're asked if we have these in place, they inspect our facility for safety, but it's up to us. We have to take responsibility. We can't just expect that

Someone's gonna regulate everything. We have to regulate ourselves and want to regulate ourselves, not just be out to make a quick buck. So I'm just gonna point out some of these minimal quality assurance procedures. ⁓ Describing the safety and efficacy of your pet food products. Organisational structure and training resources, how your staff are trained, how do you make sure your staff are continually updated in their training, especially if they're on the manufacturing line.

even if it's a family member. We are a family business and my God, my family members I think are more fearful of me when I come onto the manufacturing line that they have their safety and things in place. But they're well trained and we sign off on that and they go through ongoing training and it's important. ⁓ Hygiene procedures, process controls, pest controls, manufacturing procedures.

What else is on here that's really useful? Storage and distribution of your product procedures. Validation of records by another party. Audit management reviews, internal audits. Do you have external auditors come in? When do you do that? How often do you do that? Handling and traceability, including contact with any packaging.

Now, there's not really many dot points there. It's not much for a business to do that. It actually should have been done before you started manufacturing. But unfortunately, having spoken to many businesses, because I do ring up, I once was a consumer before we were a manufacturer, and businesses don't have these in place. And it's sad. But we're here to change that. And just a part of this is education. Go and read that. Set these procedures up. If you can't do that in-house, there are many, many companies that will help with that. But if you are a consumer,

You need to ask, you need to start asking businesses, do they have that? Some obviously will be proprietary information, but at least getting them to describe it to you, rather than share their private documentation, but describe their procedures can be a long, go a long way in helping us understand that they are compliant. Now I know pretty much every business has a HACCP plan because you can't get a licence, but if you're operating under a licence, well, that's questionable, but a HACCP plan at the very minimum.

is really important. This is our health and safety procedures. And this is what when our local inspectors come and making sure that this is up to date and compliant. ⁓ And then they're checking our facility to make sure that it's compliant with the standards that are set out in this guide. It should be updated. We update us every six months because we might have a new procedure. We might have tweaked our labeling, many, many reasons, but ⁓ once a year is the minimum.

to update it with the licensing body because that's when licenses renew once a year.

The other important thing is there is a whole list of good manufacturing practices. Now, do I think this is an exhaustive list of good manufacturing practices? Absolutely not. But it's the minimum of what constitutes good manufacturing practices. And you really should be holding ⁓ businesses to this. Yes, they might have got their license ⁓ renewed, but it's also up to us to remind them that we can report things.

⁓ and make sure that we're held to account. Other facilities maintained and clean, like ours is treated like a surgery, you're not in or out with hair nets or booty covers and it's treated so super sterile, but that's how we operate. That's not required, we're exceeding that, but these are things to ask, know, what are your minimum procedures for good manufacturing practice? You know, what footwear is going in and out of the facility? These are the things that we're asked to consider.

when we're setting up our manufacturing procedures. For example, in our facility, we have shoes that stay exclusively in our facility. Staff take their shoes off outside, they put them in a shelf, and then they walk in and they're put in manufacturing shoes, which never leave the facility and they are sterilised, washed and sterilised after each batch, because if we're changing proteins, we will clean the shoes, sterilise them, and then they'll put them back on for the next batch.

for example, so we aren't taking anything from the outside in or the inside out. If at any point they have to leave the facility, for example, to go to the bathroom, they will take those shoes off inside the facility, put their shoes on, go to the bathroom, and then when they come back, they'll swap those shoes over. In the process of re-scrubbing in as if it was a surgery, I don't care if they wash their hands in the bathroom, they will re-wash them at the hand washing basin inside the facility and follow those hand washing procedures, which is also

requirement in these minimum standards for good manufacturing practice. ⁓ What clothing is worn in the facility? They should be wearing different clothing or at least protective clothing like hair nets, gloves, aprons. The amount of videos I see on TikTok of people promoting their manufacturing business, whether it's packing food or treats and you're not even wearing a hairnet, you're not even wearing two pairs of gloves, it makes me sick because

a hair could get into that. I understand that a dog might not get sick from that, but come on, pride ourselves in what our facility standards are. It's not hard to buy a five cent hand net and make everyone wear gloves. If you walk into my facility and you're not wearing a hand net, I will kick you out. ⁓ It's just minimum. It's just getting people into a routine about these procedures. It's really, really important. ⁓

How is equipment maintained and managed? What happens if someone cuts themselves? What are these procedures? They're simple things and we would expect businesses have them. Signage, what signage is ⁓ around facilities, you know, where certain products are handled, certain products are stored? ⁓ How will we report any issues or document any issues if something goes wrong in making a batch or we have to discard a batch? How do we record all of that information?

how a visitor's managed to the manufacturing facility. And that's really important because that's where contamination can happen. These are minimum. I can think of plenty of other things, but if you're not adhering to the minimum, again, we really need to be questioning what it is we're doing. And if we're not willing to talk our customers through how we handle these things, again, why? Why can't we be transparent? What are we hiding is my question.

Okay, physical contamination. what do you, if you're using plastic, if you're using glass, if you're using wood, what are your cleaning and contamination procedures? How are you ensuring there's no cross contamination? How do you rotate your stock in where you store it? Again, if you don't have a use by date, the question whether you can accurately stock rotate because stock rotation happens on a use by date basis. So again, these are things that impact all parts of the manufacturing.

and selling process. doesn't just impact the business, it impacts the end consumer as well. Then there are lots of guidelines around what a facility must look like, how it must be set up, safety, security, disposal of waste, contamination, et cetera. We're not gonna go into that because I would assume if your licensing body has inspected you, you are compliant. Do I think that's always the case? No, I don't. I am now gonna talk about

In this, it talks about raw materials or ingredients and the purchasing of them. Now I have seen people complain about things they've found in other people's products, like bullets, where a bullet has been found in a raw pet food product and they've contacted the manufacturer and the manufacturer has simply said, one, I wouldn't know what batch that came from. And two, I wouldn't even know which supplier it came from.

That is not okay. The guidelines actually stipulate that you need to document and maintain where your raw materials come from and you need to determine if they're suitable for the next part of that manufacturing process. So if you are regularly finding bullets in your product, which I'll elaborate more on later, and you can't trace it back to where it came from, you're automatically not compliant. And to just dismiss a customer who's

Dog has eaten a bullet. Come on guys, what is wrong? Shame on these companies. I know I'm not naming them because we don't do that but, God, there's too many of them anyway. Sourcing and purchasing. Where do you get it from? What batch comes in? Have you documented it? And what batch of yours is it going out in? It's not hard but apparently it is. Now this is the minimum of what needs to be documented of incoming.

for every batch that you manufacture. Purchase order, the purchasing documentation, so the invoice, details of supplier, address of delivery, what's coming in, when did you receive it, how much was received, the batch number on their pack and the use by date. So you can then work out when you manufacture it what your use by date will be.

It also states in these guidelines that you need to retain samples of your products. Now, the reason this, I know, does not happen, is if you have to recall a product or if you need to send it for an analysis to the lab, you know that this is from batch one, this is from batch two of this product. You're not keeping samples.

How can we ever issue a proper recall? How can we ever validate what's in our products? So again, a friendly reminder that pet food companies should be keeping samples. And you guys asked, do you keep samples of every batch? I've had someone ask me that. I sent a picture of our freezer that is just a whole freezer dedicated to batch samples. And those batch samples are retained until we reach the use by date. I usually keep them for an additional three months after the use by date just to make sure.

I'm a bit busy about that, but essentially we can throw them out the use by date because they have to have been consumed by that. yeah, labeled perfectly. If we needed to, we can pull them out and send them to the lab. That should be a minimum standard guys. Documentation of any procedures and corrective action. if you, for example, needed to dispose of a batch or adjust a weight, these things should be documented.

as well. Now my favourite part, we're getting to formulations. So now we're getting into the fun of all these products that are talking about being complete and balanced, which again, I only have to look at the ingredients to know that most of these are complete lies.

when they're talking about whether their food is complete and balanced. My first red flag when a brand says they're complete and balanced and there's no detailed nutritional profile, that's probably not complete and balanced. They don't have the in-house intelligence or the nous to outsource it to someone who can whip one up for them. I'm gonna question whether you're complete and balanced. And some ingredients are just not complete and balanced. So again.

If it's not, just tell people. They'll probably still buy your product. Just stop lying about it. It just does my head in. So formulations have to be documented for every batch. So if you're completely in balance, it should be the same batch every single time. If you ask a company, what are the ratios in their product? And they cannot tell you, they're not compliant. They need to be following a formulation model, which is just common sense. It's a quality procedure.

Again, there's also basic packaging, but I'm going to spend a lot of time on labels. If your packaging's not sealed, that's usually a red flag. Or it's using packaging that just... Well, the biggest one is you can't reuse packaging. So if you're bringing a tub and filling it from your house, well, you can never complain about that food because there's no hygiene and ⁓ contamination control procedures there. ⁓

Hubs are not meant to be reused. They might be recyclable packaging, but you cannot repack into that. That's 101 in pet food standards and health and safety. We get asked all the time and we simply do not do it as much as I would love to and we're really big on trying to be environmentally friendly. There's a safety component to that. If you're bringing your dish to a warehouse to have it filled, I'm sorry, but that, while it's nice,

to be environmentally friendly. It is not compliant. There is no safety and transparency of that handling procedure. There's no temperature control over that. There's no temperature control back to that person's house. There's no guidelines on how that needs to be transported back. Now, you can say that's being over the top, but that's what the standards say. We don't want to comply to the minimum standards. Why are we manufacturing in the first place? thanks to question.

It does also stipulate in the standards about lab analysis. ⁓ not all states have these labs and there is sometimes difficulty in transporting samples to labs. It is doable, ⁓ but if required, you need to have samples to have a lab analysis done on your product. This actually should be part of a recall procedure for a business. And it's also part of the product tracking and recall. So another big thing is businesses need to have a recall procedure.

So every six months, we shut down our manufacturing line. Just to give you an example, we bring up an external auditor and we have a mock recall procedure. ⁓ Each time it's a different scenario, but what that external auditor does for us is they pick the product, they pick the batch, and they watch us go through a mock recall procedure to know that we can pull our batch records, we can work out how many

units have gone where and what we would do based on the scenario of the information we've given as to whether how far along our recall procedure we need to go. And we do that twice a year. Why? Because it matters. Do I think our product's going to be recalled? I don't know. We do everything we can, but we need to have this in place in case we do. And to show our consumers that we do everything that we can possible.

to ensure the quality and safety of our products. So again, you don't have to do that every year, but you have to have at least a procedure on how to do it. And if you don't have one, again, not sure. I'm just gonna touch on these because I wanna get to the juicy stuff, but staff training, train your staff guys.

This is it gets really good, really good guys. Labeling, marketing and nutrition. This is where the industry severely falls down because this is where profits are the priority over transparency, over compliance, over quality of nutrition. And that, that's sad because if you have a good product, it will sell.

guys, it will sell. And we owe it to our customers to be truthful to them. And if you don't have that moral compass, well, I can't change that. But maybe I can make you think about having a bit more of a moral compass in the industry. Now these guidelines too, there's a lot of leeway in them, which a lot of companies clearly opt on the end of leeway. But as I said earlier, I don't understand why you can't just be

fully transparent with our wording on our labels, with our ingredients on our labels, with our nutritional analysis, why do we have to hide things for consumers or let them guess or interpret or leave things open for interpretation? I really don't understand that. ⁓ I like to buy products where I know I have all the information accessible to me. Why should it differ in the pet food industry? And I really think we need to start questioning that as consumers, also like...

What are your values as a business if you think it's okay to do that? Food for thought, food for thought. And because it's an industry and we're all competing. No, I think when I work with new brands coming on and we do as a business because I'm passionate about this stuff in the sense that if you're gonna do the right thing, yeah, I'm gonna help you formulate a really great product. And yes, great, it's another product that's gonna be competing with mine, but I don't care essentially as long as someone else is gonna buy a good product that's transparent.

versus none. think that's where the profit should go. we really need to weigh out where our values sit in this space. So there's a table. So if you're too time poor to read all the big long labeling descriptions as to how we should label products, the very last page of the standards has a cheat sheet. I mean, goodness me.

can't be made any easier. But the thing is, this is really just in my opinion lacking. It's super minimal. at least, at least there is some guidelines. But ⁓ I think we should be going beyond this and I'm gonna show and explain why. ⁓ So basically if a ⁓ ingredient is more than 25 % of the total ingredient list, ⁓

that should be the name of the product. So if there's 25 % or more of chicken in my product, I should be calling my product Chicken Blend. If 25 % of the ingredient is not the main ingredient, but it's a variety of that ingredient, I can call it a chicken variety label. For example, chicken entree or chicken casserole. But again, why can't you just call it

chicken or chicken and chicken liver, if that's what you're doing. I just don't understand that. But the guidelines do let you get away with it, that's fine. ⁓ If two or more ingredients together comprise ⁓ up to 25%, then we should have chicken and rice, chicken and potato as the name. Again, I'm particularly big on this if it's proteins, if you've got two proteins, because this is what?

especially raw food companies are trimmers for, is just putting it as a single protein when there's multiple proteins in it. And that's not good if you've got a dog or a cat that needs a single protein. They're feeding it and still having food intolerance problems. Because you've labeled it like that. Just list all the ingredients. Make a real obvious name in your blend. ⁓ Minor ingredients is where we can then, when it's less than 3%, we can say with less than 3%.

Say with. Do I think we've got up that? Yeah, but again, just do it. So you might say lamb and beef with vegetables, or you might just stick with the proteins. I think that's being pretty transparent, but then list the vegetables. Don't just put with vegetables in your ingredient list. That really bugs me. List the ingredients. If you're seasoning cycling vegetables and you should be seasoning changing your labels,

based on the vegetables that you're putting in. ⁓ Same with awful, and I'm going to talk about that when I give you examples. It's just not necessary. Yes, it must be labelled pet food only, pet food only not for human consumption. That's a requirement even if you're using human grade. So, yeah, it's kind of unfair for those that are using human grade, hey, ⁓ that's what we need to educate.

show where our supply chain is, all those kind of things. There's also minimal nutritional information that needs to go on the packaging. Hello? Why is it not on every package? And this is not just for completes, should be on there. Should be on there. So, come on guys, it's not hard to do a metabolisable energy protein fat and any other claimed nutrients that you're marketing. You're marketing it, you must have that documentation somewhere.

Put it on your label.

Also, there's clear directions for use. How does that consumer, potentially Thor, the frozen product, or if it's a cook, what do do when they get home? How do they know what to do to handle it safely, make sure it ends up in the bowl in the right way it was intended to? It has to be on the label. Not hard, not hard at all.

Again, there should be a manufacturer date documented. So expiry date, definitely on the labels, but in your records, you need to have a date of manufacture. ⁓ Additives, additives actually are stipulated that they should be listed on your labeling. So everyone criticizes kibble companies, but hello, they actually do this. Are they the greatest additives? Probably not, but at least we know what they are. Number of raw food companies or freeze dried or gently cooked, whatever, they just say added vitamins and minerals.

Which ones? You know, there's different types of example for different types of iron. Some is more bioavailable, some is not. What type of iron? Why can't we just be transparent with what we're adding in? I don't get it. I don't understand. If you have those records, it's not hard to copy and paste that onto your label and send it to print. We really, really need to up our game. For dogs and cats, we just owe it to them.

Nutritionally complete and balanced foods. That's a whole section on this, ⁓ which specifically states it has to comply to FEDEF and AFCO. ⁓ If it's nutritionally complete, then we should be able to provide that documentation essentially. Therefore, you should be saying what added vitamins and minerals are going in it and what age and life stage it's nutritionally complete for. That all should be on our product labeling.

Now, my favorite, and it references the ACCC guys, but I know you have to be reported to the ACCC, but come on. Check your own house. Descriptive marketing terms. Okay, you make a claim that you're an organic pet food company, I would expect that you have gone through that organic licensing process. That's very misleading if you say you're organic. You might have, like we, for example, use

organic, a lot of organic ingredients, but our meat is not organic. So we cannot claim to be an organic, complete and balanced pet food company. Some is organic and we can list that to say that we, know, we are source organic, shiitake mushrooms, for example, and that's all recorded in our batch records, but I can't claim that that whole product is therefore organic, which is a shame because there's some really compliant organic.

at food companies that are doing the best and then others are coming in and out doing them in marketing and it's not fair because it's not organic.

It's also really not appropriate to tell a customer that they're getting something that they're not. Again, check your moral compass. I think it's, it's sad. I think we owe it to dogs and cats and their owners who want to learn and, you know, feed and supplement with things that benefit their health. But if we're not doing that, they can't make informed choices. So, ⁓ think about what claims are being made on your labels, but also when you get on Instagram and

tell everyone how great your product is over others, are you really making claims that aren't true? Does one herb actually do all these things that we're saying? Do you have the evidence to back that up? Do you have the science? Do you have your own testing? Do you have your own clinical trials? All these kind of things are really important for consumers to be able to understand and make those informed decision making. I want to talk about some labels now.

Again, I'm not into naming and shaming brands, I am interested in saying what I think should be improved on labels. So let's have a look.

Dr. Roz (37:19)
All right, I'm going to pop on the screen just some examples that I think are really serve a great educational purpose as to helping us see where transparency and compliance and benefiting the consumer should be the priority. Okay, so if we look at the first label, we're looking at a complete and balanced using a bath model. So again,

Bath cannot be completely balanced. that again, if we were to, there is no nutritional profile here. But if we were to look at that, we would probably question whether it should be labeled complete and balanced because bath cannot be completely balanced. That's been known for quite some time. ⁓ Beef meat. ⁓ Again, we could really push that and go, well, what part of the beef are we using trim? we using top side, using head meat, that kind of thing.

really help in transparency and again I don't see why not. Beef offal again. Not all offal is the same. You're not going to get the same nutritional profile if you put heart in one batch and liver and kidney and spleen in another batch. So what are you putting in that batch? If you're changing it because of sourcing or availability then your label needs to change. Simple as that or that batch doesn't go out. This is too general. Fresh seasonal fruit and vegetables including so

It might include this, it might include things that are not on our label. If you have pets that did really well in the first batch and then you thought, great, I'm going to buy that again. And they didn't like it. Well, the label kind of leaves it open that you might not have got the same exact product essentially because it, including carrot, broccoli and apple, but it leaves it open to interpretation, which the guidelines have said, maybe we shouldn't do has other things in it. And then we've got added vitamins and minerals.

What ones? Is it the same in this batch? The same in the next batch? What is it?

Okay, so this.

Chicken, chicken only.

No, it's not. It's chicken and lamb. And I'm going to take a guess that it's comprising more than 25%. So it should be a dual protein label on the labeling as per the requirements. And again, what lamb offal? Are you talking heart, kidney, brains, liver? What, and is that what was in the first batch versus the 217th batch? And again, what vitamins and minerals?

What vitamins and minerals? It's not hard. If we know what we're putting in there because we're following a set batch recipe in our manufacturing facility, why can't we tell our consumer that? Why cannot that consumer make an informed decision about the quality of those vitamins and minerals? Or what particular offal they want to feed their dog?

Okay. Again, I'm looking at a chicken recipe here and it includes, so it says win and winner chicken dinner or dog food. Okay, so I'm thinking it's a chicken only recipe, maybe with some fruit, vegetables, other things, but I shouldn't expect any other protein in my list. Okay, so I've got chicken. Right, then I've got turkey or chicken. Well,

Again, if we were to look at the nutritional composition of turkey versus chicken, they are not the same. They're not substitutes for each other. So what do I know whether this batch I got all chicken or this batch I got some turkey and some chicken and how much turkey and how much chicken? And then I've got mixed off of what? Turkey, chicken, duck, lamb, beef? And what organs? Because again, I can't come.

state this is a complete and balanced recipe if I'm ingredients substituting all the time. Super greens, which ones? What constitutes a super green? Mixed berries, what berries? Strawberry, raspberry, blackberry?

Okay, so it has no cheap fillers or artificial additives, but I still don't actually know what's in it. So, you know, are we better than keyboard companies? At least I know exactly what's in it. It might be shit, but at least I know it's shit and I can say, look at these ingredients, they're crap. Here, I don't even really know what protein my dog or cat's getting.

Like the name suggests, includes lamb tongue along with lamb mince plus the non-negotiables of greens and offal. But what offal? Spell it out.

Okay, again, this looks beautiful. Like, you know, this lightly cooked delicious, I like the ingredients. But I'm told this is a single protein for intolerant dogs that don't have to worry about any other protein intolerances. But the seventh ingredient is sardines, which okay, it might fit the, it's less than 3 % rule, but.

That actually says maybe we should say with beef with sardines.

So it's not single protein because fish is a protein. So again, if you're claiming something single protein, sure as hell be a single protein, but fish is a protein.

So again, you've misled your consumer. It's not fair. It is totally not fair. What if they think now their dog can't tolerate beef, but it's in fact because you put fish in it? And again, what vitamins and minerals? Vitamin minerals, we talk about kibble companies, synthetically supplement vitamins and minerals. How do I know that's not synthetic vitamins? How do I know it's not the ones that are less bioavailable for our dogs and cats to absorb? When I keep scrolling, I do find it.

tricalcium phosphate, vitamin E oil, magnesium, iron, zinc, manganese. Now, vitamin B1, manganese, iron and zinc, there is at least two to three different types of those that we can purchase and put into a product. So just saying iron, just saying zinc, is it chelate, picolate? What is it? Biclicinate.

Which one are we putting in? Cause some are mobile available or expensive. Some are super synthetic.

Again, we could be more transparent. don't understand.

Okay, my favorite chicken. Awesome chicken. Great single protein. This, this particular one is like we're all single protein. We don't put anything in. You can trust us. Awesome. I want to trust you. I want my dog and cat to have chicken. Chicken thigh. Okay, great. We're being specific. Chicken heart, chicken liver, fish oil. Bump, bump. Fish is a protein. So again, this should be chicken with fish oil.

How hard is it to be compliant?

And then again, calcium, phosphorus, iron, iodine, manganese zinc. What variety of these? There's a lot of different ones. Again, some are more bioavailable than the others.

This is just an example. And I haven't done ours because you can go and look at ours. We are so transparent with ours. ⁓ I just want to highlight that we we rubbish kibble companies, but at least they are really transparent on their labeling in terms of the ingredients. Yeah, I think the whole single protein thing is this big marketing.

scam at the moment. I think that is not limited to cable companies. I think we need to take a long hard look at raw food companies as well, fresh food companies because, but also like supplements as well. I'm just seeing some ridiculous claims there too, but

food, it's so hard to list it and have a really clear label. Like if your product is, for example, we have a product that has venison, goat, roo and lamb in it. So what did we call it? Venison, goat, roo and lamb.

We have duck and turkey with sardines. So what did we call it? Duck and turkey with sardines. We have emu with sardines. So what do we call it? Emu with sardines. And then we specifically list the rest of the ingredients. Come on, why can't we be transparent then? People picking that up know if they're reading those ingredients that okay, the dog maybe doesn't do too well with sardines. I'm not gonna buy that.

rather than them buy that, be stuck with a product they probably paid top dollar for, that they can't end up feeding, or made their dog feel unwell, or their cat feel unwell, because they didn't intentionally purchase that. They just looked at the label, which we're all guilty of doing, and then probably read it in more detail at home. Or the people selling it weren't aware either, because we weren't transparent with them as well.

real food for thought. I'm really passionate about this. It just blows my mind that we think it's okay to call out other brands and we're not looking at our own house. So I really hope this episode helps inform consumers, but also manufacturers to just go and have a look and question that if I see one more single protein and then I look at the ingredients and there's more than one protein, I literally think I should start like a

we donate a dollar because we could really save some animals because we'd probably be millionaires by the end of the week and it shouldn't be like that. So food for thought around pet food standards and also just start questioning things and asking companies, you know, what happens if...

you do this or what do you do in your facility to maintain this? Of course, internal documents are not going to be shared, talking through the procedure, but internal documents get shared when there is an audit and that's, know, who does your auditing? You know, when do you do this? When do you do that? What's your procedure for this? You know, how do you train your staff in this? you, what's your recall procedure, et cetera, et cetera. But most of these questions,

and be alleviated by having lots and lots of details on the label. The more information we can give customers, but also it gives our retailers more information. They're gonna sell more of your product if they can use that as an education tool for customers to answer the questions of what they're coming in and looking for. So food for thought, but.

Yeah, a little bit of a defense for the kibble companies who arguably have very clear transparent ingredient labels at the very least. And they do have, all have nutritional profiles. So, you know, before we throw a shard at them, have a look at your own labeling and your own in-house procedures.